sanco industries ltd share price Auditors report


Mr. Arunava Sikdar Resolution Professional

(Appointed under Insolvency & Bankruptcy Code 2016)

Sanco Industries Limited

Qualified Opinion

We have audited the accompanying standalone financial statements of SANCO INDUSTRIES LIMITED (‘the Company), which comprise the Balance Sheet as at 31 March 2023, the Statement of Profit and Loss (including other comprehensive income), Statement of Changes in Equity and Statement of Cash Flows for the year then ended and notes to the financial Statements including a summary of the significant accounting policies and other explanatory information.

In our opinion and to the best of our information and according to the explanations given to us, the aforesaid financial statements give the information required by the Companies Act, 2013 (the ‘Act) in the manner so required give a true and fair view, except on matters specified in the para below, in conformity with the accounting principles generally accepted in India, of the state of affairs of the Company as at 31 March 2023, and total comprehensive income (comprising of profit and other comprehensive income), changes in equity for the year ended on that date.

Basis for Qualified Opinion

We conducted our audit in accordance with the Standards on Auditing specified under Section 143(10) of the Act. Our responsibilities under those standards are further described in the Auditors Responsibilities for the Audit of the Financial Statements section of our report. We are independent of the Company in accordance with the Code of Ethics issued by the Institute of Chartered Accountants of India (‘ICAI) together with the ethical requirements that are relevant to our audit of the financial statements under the provisions of the Act and the rules thereunder, and we have fulfilled our ethical responsibilities in accordance with these requirements and the Code of Ethics. We believe that the financial statements give true and fair view except on the followings matters:

1. Company, at present, is under the Corporate Insolvency Resolution Process (“CIRP”) in terms of provisions of Insolvency & Bankruptcy Code, 2016(“IBC/the Code”) since 29.07.2022 vide order of the Honble National Company Law Tribunal, New Delhi. The Company has received various claims which are in excess of the amounts in the books of accounts by INR 3,360.87 lakhs. No provisioning of the same has been made in the books of accounts as at the date of Balance Sheet as the same is pending for the final order of NCLT. Summary of differences is as follows:

Particulars Claim Amount Recevied by IRP/RP (INR in Lakhs) Amount as per Books (INR in Lakhs) Difference (INR in Lakhs)
Secured Financial Creditors (Banks) 6,784.43 4,534.98 2,249.45
Employees 3.15 1.72 1.44
Govt Dues (PF& ESI) 22.76 20.06 2.70
GST Tax Demand 769.92 - 769.92
VAT Demand 293.74 - 293.74
Operational Creditors 367.14 333.25 33.89
National Stock Exchange of India 9.74 - 9.74
Total 8,250.87 4,890.00 3,360.87

2. Company has not made available to us the statement of Investments amounting to INR 46.72 lakhs, in the absence of which we are unable to comment on the existence of the asset as at the date of Balance Sheet.

3. Company has not made available to us balance confirmation pertaining to amount receivables under the following head as at the date of Balance Sheet:

a. Trade Receivable - INR 4,838.55 lakhs

b. Advances to Supplier - INR 238.01 lakhs

c. Advances to Creditor for Expenses - INR 33.22 lakhs

d. Loans & Advances (Others) - INR 525.09 lakhs

Company has not created any provision on above mentioned financial assets despite these balances being outstanding for long term. Owing to the non-availability of balance confirmation, we are unable to comment on the existence of the debt as at the date of Balance Sheet.

4. Company under the management of Resolution Professional appointed under the Insolvency & Bankruptcy Code 2016, has got Transaction Audit performed from an external entity. However, findings of the same have not been made to us for consideration.

Emphasis of Matter

We draw attention to Note 31 of Standalone Financial Statements wherein Company has current ratio of 0.04 and debt-equity ratio of -10.94 and further to Note 33(a), 33(b), 33(e) wherein it is specified that the financial statements are prepared on going concern as the CIR process is still going on. However, the prospects of the company, as such, would be determined on the completion of CIRP.

Our Opinion is not modified in respect of this matter.

Information other than the Financial Statements and Auditors Report thereon

The Companys Board of Directors is responsible for the other information. Our opinion on the financial statements does not cover the other information and we do not express any form of assurance conclusion thereon.

In connection with our audit of the financial statements, our responsibility is to read the other information and, in doing so, consider whether the other information is materially inconsistent with the financial statements or our knowledge obtained in the audit or otherwise appears to be materially misstated.

If, based on the work we have performed on the other information obtained prior to the date of this auditors report, we conclude that there is a material misstatement of this other information, we are required to report that fact. Reporting under this section is not applicable as no other information is obtained at the date of this auditors report.

Responsibilities of Management for the Financial Statements

The Companys Board of Directors is responsible for the matters stated in Section 134(5) of the Act with respect to the preparation of these financial statements that give a true and fair view of the financial position, financial performance and cash flows of the Company in accordance with the accounting principles generally accepted in India, including the Accounting Standards prescribed under Section 133 of the Act, read with Rule 7 of the Companies (Accounts) Rules, 2014 (as amended). This responsibility also includes maintenance of adequate accounting records in accordance with the provisions of the Act for safeguarding the assets of the Company and for preventing and detecting frauds and other irregularities; selection and application of appropriate accounting policies; making judgments and estimates that are reasonable and prudent; and design, implementation and maintenance of adequate internal financial controls, that were operating effectively for ensuring the accuracy and completeness of the accounting records, relevant to the preparation and presentation of the financial statements that give a true and fair view and are free from material misstatement, whether due to fraud or error.

In preparing the financial statements, management is responsible for assessing the Companys ability to continue as a going concern, disclosing, as applicable, matters related to going concern and using the going concern basis of accounting unless management either intends to liquidate the Company or to cease operations, or has no realistic alternative but to do so.

Auditors Responsibilities for the Audit of the Financial Statements

Our objectives are to obtain reasonable assurance about whether the financial statements as a whole are free from material misstatement, whether due to fraud or error, and to issue an auditors report that includes our opinion. Reasonable assurance is a high level of assurance, but is not a guarantee that an audit conducted in accordance with Standards on Auditing will always detect a material misstatement when it exists. Misstatements can arise from fraud or error and are considered material if, individually or in the aggregate, they could reasonably be expected to influence the economic decisions of users taken on the basis of these financial statements.

As part of an audit in accordance with Standards on Auditing, we exercise professional judgment and maintain professional skepticism throughout the audit. We also:

• Identify and assess the risks of material misstatement of the financial statements, whether due to fraud or error, design and perform audit procedures responsive to those risks, and obtain audit evidence that is sufficient and appropriate to provide a basis for our opinion.

• The risk of not detecting a material misstatement resulting from fraud is higher than for one resulting from error, as fraud may involve collusion, forgery, intentional omissions, misrepresentations, or the override of internal control.

• Obtain an understanding of internal control relevant to the audit in order to design audit procedures that are appropriate in the circumstances. Under section 143(3)(i) of the Act, we are also responsible for expressing our opinion on whether the Company has adequate internal financial controls system in place and the operating effectiveness of such controls.

• Evaluate the appropriateness of accounting policies used and the reasonableness of accounting estimates and related disclosures made by management.

• Conclude on the appropriateness of managements use of the going concern basis of accounting and, based on the audit evidence obtained, whether a material uncertainty exists related to events or conditions that may cast significant doubt on the Companys ability to continue as a going concern. If we conclude that a material uncertainty exists, we are required to draw attention in our auditors report to the related disclosures in the financial statements or, if such disclosures are inadequate, to modify our opinion. Our conclusions are based on the audit evidence obtained up to the date of our auditors report. However, future events or conditions may cause the Company to cease to continue as a going concern.

• Evaluate the overall presentation, structure and content of the financial statements, including the disclosures, and whether the financial statements represent the underlying transactions and events in a manner that achieves fair presentation.

We communicate with those charged with governance regarding, among other matters, the planned scope and timing of the audit and significant audit findings, including any significant deficiencies in internal control that we identify during our audit.

We also provide those charged with governance with a statement that we have complied with relevant ethical requirements regarding independence, and to communicate with them all relationships and other matters that may reasonably be thought to bear on our independence, and where applicable, related safeguards.

Report on Other Legal and Regulatory Requirements

1. As required by Section 143(3) of the Act, we report that:

a. we have sought and obtained all the information and explanations which to the best of our knowledge and belief were necessary for the purpose of our audit;

b. in our opinion, proper books of account as required by law have been kept by the Company so far as it appears from our examination of those books;

c. the financial statements dealt with by this report are in agreement with the books of account;

d. in our opinion, the aforesaid financial statements comply with the Accounting Standards prescribed under Section 133 of the Act, read with Rule 7 of the Companies (Accounts) Rules, 2014 (as amended);

e. we could not get any written representations from the directors as on 31st March 2023 and unable to comment on whether any director is disqualified or not as on 31 March 2023 from being appointed as a director in terms of Section 164(2) of the Act;

f. With respect to adequacy of the internal financial controls over financial reporting of the company with reference to these financial statements and the operating effectiveness of such controls, refer to our separate report in ‘Annexure B to this report; and

g. with respect to the other matters to be included in the Auditors Report in accordance with Rule 11 of the Companies (Audit and Auditors) Rules, 2014 (as amended), in our opinion and to the best of our information and according to the explanations given to us:

i. the Company, at present, is under the Corporate Insolvency Resolution Process (“CIRP”) in terms of provisions of Insolvency & Bankruptcy Code, 2016(“IBC/the Code”) since 29.07.2022 vide order of the Honble National Company Law Tribunal, New Delhi.

ii. the Company did not have any long-term contracts including derivative contracts for which there were any material foreseeable losses as at 31 March 2023;

iii. there were no amounts which were required to be transferred to the Investor Education and Protection Fund by the Company during the year ended 31 March 2023,

As required by the Companies (Auditors Report) Order, 2020 (“the Order”), issued by the Central Government of India in terms of sub-section (11) of section 143 of the Act, we give in the Annexure A, statement on the matters specified in paragraphs 3 and 4 of the Order.

For K. G. Sharma & Co.

Chartered Accountants

Firm registration number: 005240N

Sanjeev Kumar Jain

Partner

Membership No.: 089416

UDIN: 23089416BGYMXN8620

Place: Delhi

Date: 31/05/2023

ANNEXURE ‘A TO INDEPENDENT AUDITORS REPORT

(Referred to in paragraph 1 of the Independent Auditors report of even date to the members of M/s SANCO INDUSTRIES LIMITED on the Financial Statements as on and for the year ended 31st March 2023.)

i.

a. The Company has maintained proper records showing full particulars, including quantitative details and situation of property, plant and equipment.

b. According to the information and explanation given to us and physical verification of property, plant and equipment was conducted by Interim Resolution Professional during the year. However, no reconciliation was prepared of physical assets vis-a-vis books assets. Hence, we are unable to comment on whether any discrepancy was noted or not.

c. According to the information and explanations given to us and on the basis of our examination of the records of the Company, the title deeds of immovable properties disclosed in the standalone financial statements is held in the name of the Company.

d. According to the information and explanations given to us and on the basis of our examination of the records of the Company, the Company has not revalued its property, plant and equipment (including right of use assets) or intangible assets or both during the year.

e. According to information and explanations given to us and on the basis of our examination of the records of the Company, there are no proceedings initiated or pending against the Company for holding any benami property under the Prohibition of Benami Property Transactions Act, 1988 and rules made thereunder.

ii.

a. The inventory has been physically verified by the Interim Resolution Professional appointed under the Insolvency & Bankruptcy Code, 2016 during the year. However, no reconciliation was prepared of physical inventory vis-a-vis books inventory. Hence, we are unable to comment on whether any discrepancy was noted or not. Further, we are also unable to comment on the valuation of the inventory in the absence of the valuation report.

b. According to the information and explanations given to us, the Company has not been sanctioned working capital limits from banks or financial institutions in excess of INR 5 crores. Accordingly, clause 3(ii)(b) of the Order is not applicable.

iii. According to the information and explanations given to us and on the basis of our examination of the records of the Company, during the year, the Company has neither made any investments, nor provided any guarantee or security or granted any loans or advances in the nature of loans, secured or unsecured, to companies, firms, Limited Liability Partnerships or any other parties. Accordingly, clause (iii)(a) to clause (iii)(f) of the Order are not applicable.

iv. According to the information and explanations given to us and on the basis of our examination of records of the Company, the Company has neither made any investments, nor provided any guarantee or security or granted any loans or advances. Hence, provisions of Section 185 and 186 of the Companies Act, 2013 (“the Act”) was not required to be complied with. Accordingly, clause (iv) of the Order is not applicable.

v. The Company has accepted deposits in contravention of Section 73 to Section 76 of Companies Act 2013 read with Companies (Acceptance of Deposit) Rules 2014 details of which are as follows:

Name of the Party Relationship Amount (In Lakhs) Reason of Non-Compliance
Shakuntla Gupta Relative of Director 18.50 Receipt of loan from Relative of Director by Public Limited Company

Further, Company also has outstanding loans in contravention of the aforementioned sections, details of which are as follows:

Name of the Party Relationship Amount (In Lakhs) Remarks
Anurag Gupta Relative of Director 48.50 Outstanding Loan from Relative of Directors of a Public Limited Comapany in contraventionn of Sec 73 to Sec 76 of Companies Act 2013 read with Deposit Rules.
Mansi Gupta Relative of Director 25.00
Rita Gupta Relative of Director 240.00
Shakuntla Gupta Relative of Director 138.50
Total 452.00

vi. According to the information and explanations given to us, the Central Government has not prescribed the maintenance of cost records under sub-section (1) of Section 148 of the Companies Act, 2013, for any of the services rendered or goods sold by the Company. Accordingly, clause 3(vi) of the Order is not applicable.

vii.

a. The Company does not have liability in respect of service tax, duty of excise and sales tax during the year since effective July 01, 2017, these statutory dues has been subsumed into goods and services tax.

According to the information and explanations given to us and on the basis of our examination of the records of the Company, in our opinion, amounts deducted/accrued in the books of account in respect of undisputed statutory dues including goods and services tax, provident fund, employees state insurance, income-tax, duty of customs, value added tax, cess and other statutory dues have not been regularly deposited by the Company with the appropriate authorities, delays of which are material.

According to the information and explanations given to us and on the basis of our examination of the records of the Company, undisputed amounts payable in respect of goods and services tax, provident fund, employees state insurance, income-tax, duty of customs, value added tax, cess and other statutory dues in arrears as at March 31, 2023 for a period of more than six months from the date they became payable.

S.No. Name of the Liability Amount (in Lacs)
1 Provident Fund 12.54
2 ESI 7.51
3 Income Tax Payable 303.92

b. According to the information and explanations given to us and on the basis of our examination of the records of the Company, no statutory dues relating to goods and services

S.No. Name of the Statute Nature of Dues Forum where dispute is pending Period to which amount relates Amount (In Lakhs)
1 Income Tax Act, 1961 Income Tax CIT (Appeals) AY 14-5 63.33 (Order passed in favour of company)
2 Income Tax Act, 1961 Income Tax CIT (Appeals) AY 12-13 Copy of assessment order not provided by management
3 Income Tax Act, 1961 Income Tax CIT (Appeals) AY 17-18 Copy of assessment order not provided by management

viii. According to the information and explanations given to us and on the basis of our examination of the records of the Company, the Company has not surrendered or disclosed any transactions, previously unrecorded as income in the books of account, in the tax assessments under the Income tax Act, 1961 as income during the year.

ix.

a. According to the information and explanations given to us and on the basis of our examination of the records of the Company, the Company has defaulted in repayment of loans and borrowings and in the payment of interest thereon to lenders.

Name of Bank Nature of Dues Amount (INRIn Lakhs) Due Date Status
South India Bank (CC A/c) Principal & Interest 1,363.76 Various dates The Companys bank account has become Non- Performing Asset (NPA) as per banking rules and regulations.
UBI Delhi (CCA/C) Principal & Interest 3,127.79 Various dates The Companys bank account has become Non- Performing Asset (NPA) as per banking rules and regulations.
Aditya Birla Finance Limited Principal & Interest 46.00 Various dates The Company is irregular in paying the outstanding amount.
Total 4,537.55

b. According to the information and explanations given to us and on the basis of our examination of the records of the Company, the Company has not been declared a wilful defaulter by any bank or financial institution or government or government authority.

c. According to the information and explanations given to us and on the basis of our examination of the records of the Company, the Company has neither obtained term loan

nor had any outstanding balance at the beginning of the year. Accordingly clause (ix)(c) of the Order is not applicable.

d. According to the information and explanation given to us and on the basis of our examination of the records of the Company, we believe the Company has not used funds raised on short-term basis for long-term purposes.

e. According to the information and explanations given to us and on an overall examination of the standalone financial statements of the Company, we report that the Company has not taken any funds from any entity or person on account of or to meet the obligations of its subsidiaries or joint venture as defined under Companies Act, 2013.

f. According to the information and explanations given to us and procedures performed by us, we report that the Company has not raised loans during the year on the pledge of securities held in its subsidiaries or joint venture (as defined under Companies Act, 2013).

x.

a. The Company has not raised any moneys by way of initial public offer or further public offer (including debt instruments). Accordingly, clause 3(x)(a) of the Order is not applicable.

b. According to the information and explanations given to us and on the basis of our examination of the records of the Company, the Company has not made any preferential allotment or private placement of shares or fully or partly convertible debentures during the year. Accordingly, clause 3(x)(b) of the Order is not applicable.

xi.

a. The Resolution Professional, appointed by The Honble National Company Law Tribunal, has got Transaction Audit performed by an external entity and the findings of same have not been shared with us citing the confidentiality imposed by the provisions of Insolvency & Bankruptcy Code 2016. Accordingly, we are unable to comment on whether the fraud by the Company or on the Company was committed or reported during the year.

b. According to the information and explanations given to us, no report under sub-section (12) of Section 143 of the Companies Act, 2013 has been filed by the auditors in Form ADT-4 as prescribed under Rule 13 of the Companies (Audit and Auditors) Rules, 2014 with the Central Government.

c. As represented to us by the management, there are no whistle blower complaints received by the Company during the year.

xii. According to the information and explanations given to us, the Company is not a nidhi company. Accordingly, clause 3 (xii) of the Order is not applicable.

xiii. In our opinion and according to the information and explanations given to us, the transactions with the related parties are not in compliance with Section 177 and 188 of the Companies Act, 2013 where applicable and however the details of the related party transactions have been disclosed in the standalone financial statements as required by the applicable accounting standards.

xiv.

a. In the absence of complete information and explanations and based on our audit procedures, we are unable to comment on whether the Company has an adequate internal audit system considering the size and nature of its business.

b. No Internal audit report has been made available to us for consideration.

xv. In our opinion and according to the information and explanations given to us, the Company has sold asset (car) to director and person connected with director against their outstanding loans which are in our opinion covered under the provisions of Section 192 of the Companies Act, 2013. Based on the information and explanation given to us, no approval for the same was obtained in a general meeting of the Company. Details of transactions are as follows:

Asset Name Transaction Type Name of Party Relationship Amount (InLakhs)
Honda Civic Car Sale Sanjay Gupta Director 0.58
Maruti Car (Alto K 10) Sale Sanjay Gupta Director 0.29
Honda City Car Sale Sidhant Gupta Person Connected with Director 2.82

xvi.

a. The Company is not required to be registered under Section 45-IA of the Reserve Bank of India Act. 1934. Accordingly, clause 3(xvi)(a) of the Order is not applicable.

b. The Company is not required to be registered under Section 45-IA of the Reserve Bank of India Act, 1934. Accordingly, clause 3(xvi)(b) of the Order is not applicable.

c. The Company is not a Core Investment Company (CIC) as defined in the regulations made by the Reserve Bank of India. Accordingly, clause 3(xvi)(c) of the Order is not applicable.

d. According to the information and explanations given to us, there is no core investment company within the Group (as defined in the Core Investment Companies (Reserve Bank) Directions, 2016). Accordingly, the clause 3(xvi)(d) of the Order is not applicable.

xvii. The Company has incurred cash losses of INR 19.34 Crores in the current financial year and INR 52.89 lakhs in the immediately preceding financial year.

xviii. There has been no resignation of the statutory auditors during the year. Accordingly, clause 3(xviii) of the Order is not applicable.

xix. The Company, at present, is under the Corporate Insolvency Resolution Process (“CIRP”) in terms of provisions of Insolvency & Bankruptcy Code, 2016(“IBC/the Code”) since 29.07.2022. The Company has already defaulted on loans repayment. According to the limited information and explanations given to us and on the basis of the financial ratios, ageing and expected dates of realisation of financial assets and payment of financial liabilities, other information accompanying the standalone financial statements and management plans and based on our examination of the evidence supporting the assumptions, we believe that material uncertainty exists as on the date of the audit report that Company is not capable of meeting its liabilities existing at the date of balance sheet as and when they fall due within a period of one year from the balance sheet date. We further state that our reporting is based on the facts up to the date of the audit report.

xx. In our opinion and according to the information and explanations given to us, there is no unspent amount under sub-section (5) of Section 135 of the Companies Act, 2013 pursuant to any project. Accordingly, clauses 3(xx)(a) and 3(xx)(b) of the Order arc not applicable.

xxi. The Company is holding company of ‘Sanjita Polmet Limited. No signed Financials Statements with the Auditors report have been made available to us. Hence, we are unable to comment on whether there was any qualification or adverse remark was made by their respective auditor.

For K. G. Sharma & Co.

Chartered Accountants

Finn registration number: 005240N

Sanjeev Kumar Jain

Partner

Membership No.: 089416

UDIN: 23089416BGYMXN8620

Place: Delhi

Date: 31/05/2023

ANNEXURE FT TO INDEPENDENT AUDITORS REPORT

(Referred to in paragraph 1(1) under ‘Report on Other Legal and Regulatory Requirements section of our report to the Members of SANCO INDUSTRIES LIMITED of even date)

Report on the Internal Financial Controls Over Financial Reporting under Clause (i) of Sub-section 3 of Section 143 of the Companies Act, 2013 (“the Act”)

We have audited the internal financial controls over financial reporting of SANCO INDUSTRIES LIMITED (the “Company”) as of March 31st ,2023 in conjunction with our audit of the standalone financial statements of the Company for the year ended on that date.

Managements Responsibility for Internal Financial Controls

The Board of Directors of the Company is responsible for establishing and maintaining internal financial controls based on the internal control over financial reporting criteria established by the Company considering the essential components of internal control stated in the Guidance Note on Audit of Internal Financial Controls Over Financial Reporting issued by the Institute of Chartered Accountants of India (the “ICAI”). These responsibilities include the design, implementation and maintenance of adequate internal financial controls that were operating effectively for ensuring the orderly and efficient conduct of its business, including adherence to the respective companys policies, the safeguarding of its assets, the prevention and detection of frauds and errors, the accuracy and completeness of the accounting records, and the timely preparation of reliable financial information, as required under the Companies Act, 2013.

Auditors Responsibility

Our responsibility is to express an opinion on the Companys internal financial controls over financial reporting of the Company based on our audit. We conducted our audit in accordance with the Guidance Note on Audit of Internal Financial Controls Over Financial Reporting (the “Guidance Note”) issued by the ICAI and the Standards on Auditing prescribed under Section 143(10) of the Companies Act, 2013, to the extent applicable to an audit of internal financial controls. Those Standards and the Guidance Note require that we comply with ethical requirements and plan and perform the audit to obtain reasonable assurance about whether adequate internal financial controls over financial reporting was established and maintained and if such controls operated effectively in all material respects.

Our audit involves performing procedures to obtain audit evidence about the adequacy of the internal financial controls system over financial reporting and their operating effectiveness. Our audit of internal financial controls over financial reporting included obtaining an understanding of internal financial controls over financial reporting, assessing the risk that a material weakness exists, and testing and evaluating the design and operating effectiveness of internal control based on the assessed risk. The procedures selected depend on the auditors judgment, including the assessment of the risks of material misstatement of the financial statements, whether due to fraud or error.

We could not get sufficient and appropriate audit evidences to provide a basis for our audit opinion on the Companys internal financial controls system over financial reporting.

Meaning of Internal Financial Controls over Financial Reporting

A companys internal financial control over financial reporting is a process designed to provide reasonable assurance regarding the reliability of financial reporting and the preparation of financial statements for external purposes in accordance with generally accepted accounting principles. A companys internal financial control over financial reporting includes those policies and procedures that (1) pertain to the maintenance of records that, in reasonable detail, accurately and fairly reflect the transactions and dispositions of the assets of the company; (2) provide reasonable assurance that transactions are recorded as necessary to permit preparation of financial statements in accordance with generally accepted accounting principles, and that receipts and expenditures of the company are being made only in accordance with authorizations of the management and directors of the company; and (3) provide reasonable assurance regarding prevention or timely detection of unauthorized acquisition, use, or disposition of the companys assets that could have a material effect on the financial statements.

Inherent Limitations of Internal Financial Controls over Financial Reporting

Because of the inherent limitations of internal financial controls over financial reporting, including the possibility of collusion or improper management override of controls, material misstatements due to error or fraud may occur and not be detected. Also, projections of any evaluation of the internal financial controls over financial reporting to future periods are subject to the risk that the internal financial control over financial reporting may become inadequate because of changes in conditions, or that the degree of compliance with the policies or procedures may deteriorate.

Opinion

In our opinion, to the best of our information and according to the explanations given to us, we are not in position to comment on whether the Company has an adequate internal financial controls system over financial reporting and whether such internal financial controls over financial reporting were operating effectively as at March 31st, 2023.

For K. G. Sharma & Co.

Chartered Accountants

Firm registration number: 005240N

Sanjeev Kumar Jain

Partner

Membership No.: 089416

UDIN: 23089416BGYMXN8620

Place: Delhi

Date: 31/05/2023